Thesis (Ph. D.)--University of Alberta, 2010. / Title from pdf file main screen (viewed on February 1, 2010). A thesis submitted to the Faculty of Graduate Studies and Research in partial fulfillment of the requirements for the degree of Doctor of Philosophy in Accounting, School of Business. At head of title: University of Alberta. Spring 2009. Includes bibliographical references.

Thesis (LL. M.)--Judge Advocate General's School, U.S. Army, 1973. / "April, 1973." Typescript. Includes bibliographical references. Also issued in microfiche.

Thesis (M.B.A.)--University of Hong Kong, 1998. / Includes bibliographical references (leaf 91).

Thesis (doctoral)--Universität Münster.

Thesis (Ph. D.)--Ohio State University, 1976. / Includes bibliographical references (leaves 143-145). Available online via OhioLINK's ETD Center.

University of Macau / Faculty of Business Administration. / Department of Accounting and Information Management

Section 245 was proposed as part of the tax reform package initiated by the government on 18 June, 1987. It introduced an extended general anti-avoidance rule into Canadian tax law. The rule has been in effect since September 13, 1988, but has yet to be judicially considered. This paper adopts a methodology which incorporates a political perspective. In particular, the rule is analyzed within the general environment - the socio-political, economic and historical backgrounds - in existence at that time. It was felt that such an approach was necessary to explain certain issues. For example, why the Canadian government decided to introduce section 245 and why certain modifications were made to the proposal in its passage through the legislative process. Overall, this paper hopes to extend our understanding of the rule by exposing the factors which created a favourable political environment for the enactment of the provision.

South Africans emerged from the darkness and entered the into the light of freedom in 1994 when the first democratic elections where held in South Africa. This liberty was entrenched with the signing of the Constitution in December 1996 by President Nelson Mandela at Sharpeville. Taxpayers have also benefitted under the Constitution. This dissertation examines the Constitution and how it applies to taxpayers and their rights. It examines the legislation which regulates the tax authorities and how they apply this legislation. It then examines the rights of taxpayers and how the Constitutional Court interprets the Constitution in respect of taxpayers rights. The dissertation also examines the remedies that taxpayers have when they feel that their rights have been encroached upon. The correct order that should be followed by taxpayers in protecting their rights is discussed. Recent proposals announced by the tax authorities, in an attempt to assist taxpayers, are examined. Finally, common law and practical problems that face taxpayers are discussed and thereafter a short conclusion is drawn as to the rights of taxpayers. / Thesis (M.Com.)-University of KwaZulu-Natal, Durban, 2004.

In this dissertation, I examine two related questions on whether and how tax aggressiveness of firms is associated with shareholder wealth in a new context – mergers and acquisitions (M&A). The first study investigates whether and how the tax aggressiveness of the acquirers and targets affects shareholder wealth. I present the idea of tax aggressiveness transfer whereby the acquirer’s propensity for tax planning applies to its target’s tax function after the change in ownership. I measure the degree of tax aggressiveness transfer using the relative tax aggressiveness of the acquirer and target (i.e., the difference in tax aggressiveness between the two firms). I find that acquisitions of more tax aggressive targets by less tax aggressive acquirers generate significantly lower acquisition gains. I also document weaker evidence that acquisitions of less tax aggressive targets by more tax aggressive acquirers generate higher acquisition gains. That is, the results suggest that the shareholder wealth effects of tax aggressiveness transfer are driven by the value-destroying effect of decreases in tax aggressiveness. Cross-sectional analyses reveal that the acquirer’s governance is a significant determinant of the shareholder wealth effects of tax aggressiveness transfer. Specifically, the results indicate that, when acquirers are well-governed, acquisitions of targets with lower tax aggressiveness by acquirers with higher tax aggressiveness are value-enhancing. Similarly, acquisitions of targets with higher tax aggressiveness by acquirers with lower tax aggressiveness are value-destroying. These findings are robust to various measures of tax aggressiveness. In sum, I find that tax aggressiveness transfer is a significant determinant of value creation or destruction in M&A. The second study is devoted to studying whether and how the target’s participation of tax shelters – an extreme form of tax aggressiveness – matters in acquirer’s valuation of the target firm. Using a novel dataset that identifies targets’ non-participation in tax shelters, I find that the target’s non-sheltering status is associated with a higher takeover premium, indicating that acquirers reward targets for not engaging in tax sheltering. This positive association is stronger for targets that are more opaque and for acquirers that are less tax aggressive. In addition, I find that the target’s non-sheltering status is positively associated with acquirer returns for acquirers that are weakly governed and for targets that are more opaque. Overall, my findings suggest that the target’s non-sheltering status is relevant in acquirers’ valuation of the target, and that the valuation benefits of the target’s non-participation in tax shelters are mainly accrued to the target’s own shareholders rather than to those of the acquiring firm.

Section 245 was proposed as part of the tax reform package initiated by the government on 18 June, 1987. It introduced an extended general anti-avoidance rule into Canadian tax law. The rule has been in effect since September 13, 1988, but has yet to be judicially considered. This paper adopts a methodology which incorporates a political perspective. In particular, the rule is analyzed within the general environment - the socio-political, economic and historical backgrounds - in existence at that time. It was felt that such an approach was necessary to explain certain issues. For example, why the Canadian government decided to introduce section 245 and why certain modifications were made to the proposal in its passage through the legislative process. Overall, this paper hopes to extend our understanding of the rule by exposing the factors which created a favourable political environment for the enactment of the provision. / Law, Peter A. Allard School of / Graduate